STIPULATION FOR CONTINUANCE OF JUDGMENT AND SENTENCING; PROPOSED ORDER CURRENT HEARING: [6-15-12] PROPOSED HEARING: [8-3-12]

Plaintiff United States of America, by and through its attorneys of record, Assistant U.S. Attorneys CAMIL SKIPPER and AUDREY HEMESETH, and defendant LORI ZOVAL, both individually and by and through her counsel of record, MARK REICHEL, hereby stipulate as follows:

1. Defendant pleaded guilty to Count 1 on October 21, 2011. Judgment and sentencing were set for January 6, 2012, at which time defendant was allowed to remain on pretrial release.

2. By this stipulation, the parties jointly move to continue judgment and sentencing to August 3, 2012, at 9:00 A.M. This is the fifth request for a continuance.

3. The parties request the continuance based upon the following facts:

a. The probation officer is scheduled to interview defendant on May 30, 2012.

b. The probation officer believes a hearing on August 3, 2012, will allow sufficient time to complete the draft Presentence Report and allow for informal and formal objections to the Report.

4. The government has stated that it is disinclined to agree to further continuances of the sentencing hearing without a status hearing before the Court.

IT IS SO STIPULATED.

ORDER

The following sentencing schedule shall be observed:

Judgment and Sentencing Date: August 3, 2012 ...

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